I.Export tax refundWhat are the basic conditions?

According to the latest Value-added Tax and Consumption Tax Management Measures for Export Goods and Services 2025, applyExport tax refundThe following conditions must be met at the same time:

• Subject Qualification RequirementsThe declaring unit must be the import and export enterprise of the customs registration record.
• Identification of the corresponding principle: The customs declaration form, VAT invoice, and foreign exchange receipt must be "triple-matched".
• time restrictionsAfter the export of goods, the declaration must be completed before the VAT declaration period of the following year4

What are the specific mechanisms of operating agency exports?

In the typical agent export model, the actual trade relationship presents a double attribute:

• Legal level: agency asShipping units on the Customs BillSubject responsibility for exports
• Commercial level: The client (producing enterprises) actually controlsProperty of goodsandTransaction Pricing Rights

suchThe separation between "nominal export" and "actual transaction"According to the case of a Jiangsu textile enterprise that we have served, when it exports goods worth $50$,000 through an agent company, the subjects of customs clearance and exchange are the agency companies, forming a complete chain of proof of tax refund.

Why cant the agent exporter apply for tax refund?

Combined with the typical tax inspection cases of three years, we found that the key complications of non-refundable taxes are:

• The value added tax chain is brokenProduction enterprises issued invoices to the agency, but the actual goods have not been sold to the agency
• Money flows into contradiction.Foreign goods directly paid to the account of the agency, with the lack of direct transaction credentials with the production enterprise
• Risk Control Supervision: The State Taxation Administration has placed special emphasis in 2024 on preventing fraudulent tax refund schemes involving "fake self-operation and real agency."

How to obtain export tax refund legally?

Based on 20 years of practical experience, it is recommended that companies choose the appropriate path according to the development phase:

• Option 1: Apply for Import and Export Operating Rights
  • Registered funds50 million from RMB
  • Treatment of customs registration and electronic ports
• Plan 2: Establish a Real Purchase Relationship
  • Signing formal procurement contracts with agencies
  • Ensure funds settle through public accounts and issue compliant invoices
• Option 3: Using the Integrated Services Platform for Foreign Trade
  • Choose a qualified enterprise.
  • Retain a complete chain of evidence through the "online + data-driven" model.

V. Common Mistakes and Risk Signs

Recently, we have found that three categories of high-risk operations require special attention:

• Export payments:2025 The customs has seized the case related to37, the maximum penalty value of the delivered goods200%
• Invoices arrivedSome enterprises have attempted to deduct export tax refunds with in-house sales invoices, this operation has been clearly defined as tax fraud.
• borrowed account: Utilizing a third-party company for foreign exchange collection will result in "inconsistent three flows," potentially triggering verification by the foreign exchange administration.